Case library / Discipline that arrives from somewhere else
The floor of the sanction ladder
In short
Public Reproval - the only public reprimand of an MFT in the 2024-2026 data, and the mildest formal discipline in the en
Public reprovalA public reproval — the mildest formal outcome available, and the only one in three years.
The mildest formal discipline available, and the only one issued to an MFT in three years of data — which is why the whole sanction ladder is worth knowing.
What happened
The Medical Board of California publicly reprimanded the licensee's physician's certificate for unprofessional conduct and repeated negligent acts with a patient, requiring 40 hours of continuing medical education and cost recovery.
BBS charged that discipline under §4982.25(a) against the MFT license.
What it was charged as
Discipline by another California healing-arts board.
The outcome
Public Reproval — the only public reprimand of an MFT in the 2024–2026 data, and the mildest formal discipline in the entire set. Cost recovery payable in full within 90 days.
Cost recovery: Ordered, payable within 90 days.What the rule actually says
It is worth knowing the whole ladder, because most therapists only ever hear about the top of it. In ascending order: a citation and fine, which is not formal discipline; a public reproval; probation, typically three to five years; suspension; surrender; revocation. In four years of Board data there were three public reprovals in total across every license type, and between 7 and 26 revocations a year.
Discussion
Analysis, not part of the decision
Most therapists have heard of revocation and of probation and know nothing in between. The ladder, in ascending order, runs: a citation and fine, which is not formal discipline at all; a public reproval; probation, typically three to five years; suspension; surrender; revocation. In four years of Board data there were three public reprovals across every license type the Board regulates, and between 7 and 26 revocations a year.
The origin of this one is the same pattern as the two cases before it: the Medical Board publicly reprimanded a physician's certificate, and BBS charged that discipline under §4982.25(a) against the MFT license. Three cases in this group, three different originating boards, one statute.
A public reproval is still public and still formal. It appears on the license record and is disclosable. It is the floor, not an absence of consequence.
Where insurance reaches, and where it does not
A public reproval is still public, and still reportable to every payer panel and credentialing body you belong to. The cost of getting there — counsel, the response, the negotiation — is what board defense pays for, and the outcome is the argument for spending it.
What would have changed it
- The distance between a reproval and probation is usually the quality of the response, not the gravity of the conduct. That response is the thing worth paying a licensing attorney for.
Questions
For a law and ethics seminar, or for yourself
- Place each sanction on the ladder and say what a licensee may still do at each level.
- Given how rare a public reproval is, what would you infer about the circumstances required to obtain one?
- How does a citation and fine differ from formal discipline in terms of what a future employer or payer can see?
Source. This write-up is drawn from the signed public decision in the case number above. Names, cities and employers have been removed — why. To pull the original, open the Board's quarterly newsletter archive, find the issue covering March 6, 2025, and match the case number in the Formal Disciplinary Actions section. Not legal advice.
